The Independent Commission for the Reform of International Corporate Taxation (ICRICT) has issued a report comparing the OECD and UN versions of a Subject to Tax Rule (STTR). Both versions essentially allow a source state to impose a minimum level of taxation on payments under tax treaties where the payment is subject to low or no taxation in the state of the payee. In the report, the ICRICT recommends that developing companies introduce the UN STTR in their tax treaties. --- INTRODUCTION The past few decades have seen a rapid increase in the amount of double tax treaties signed between...